The Court of Criminal Appeal has been told former doctor Graeme Reeves needs to be on dialysis and can't get the proper treatment he needs in jail.

Tracey Nearmey: AAP

A Sydney court has heard a former gynaecologist who mutilated a woman's genitals should not go back to jail because of his poor health.

Graeme Reeves was released on parole in 2013 after serving part of his two-and-a-half-year jail sentence for removing a patient's clitoris without her consent during an operation to take out a pre-cancerous lesion.

He was found guilty in 2011 of maliciously inflicting grievous bodily harm on Carolyn DeWaegeneire at Bega on the New South Wales south coast.

In December last year, the High Court overturned a decision to increase his jail time by 18 months because of his deteriorating health.

It sent the case back to the Court Of Criminal Appeal to reconsider the sentence.

His lawyer has told the Court of Criminal Appeal that Reeves needs to be on dialysis and can not get the proper treatment he needs in jail.

The court has reserved its decision until a later date.

Reeves sat in court just metres away from Ms DeWaegeneire.

Outside court she said she hoped his sentence was increased.

"The legal system is geared towards the perpetrators," she said.

Commenting on reports that more than 60 other charges were dropped against Reeves last year due to insufficient evidence, she said: "It's appalling... it's a slap in the face for police who investigated him."

Lorraine Long, an advocate for Reeves' patients, said many of the women who complained about him have had trouble getting legal representation.